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Automated License Plate Recognition (ALPR) Usage and Privacy Policy

Updated: June 28, 2024

This Automated License Plate Recognition (“ALPR”) Usage and Privacy Policy (“Policy”) governs the ALPR system (“ALPR System”) operated by Murphy’s Bowl LLC, also doing business as Halo Sports and Entertainment, on behalf of itself, LA Clippers LLC, Forum Entertainment LLC, and Clippers G League LLC (collectively “MB,” “we,” “us,” or “our”) to secure the parking facilities at and around the “Intuit Dome” and the “Kia Forum” located in Inglewood, California (“Parking Facilities”).  We have developed this Policy to tell you how and why we collect and use ALPR Information in accordance with California Civil Code § 1798.90.5, et seq.

Acceptance

Please read this Policy carefully. By accessing the Parking Facilities, you are accepting the terms of this Policy, which may be updated and amended from time to time.

What Is the ALPR System?

The ALPR System is a searchable computerized database resulting from the operation of one or more mobile or fixed cameras combined with computer algorithms to read and convert images of registration plates and the characters they contain into computer-readable data. The information contained in the ALPR System (“ALPR Information”) includes still images of the backside of vehicles including license plates, plus the date and time when the images were collected, and the license plate characters and numbers associated with the image.

Who Is Authorized To Use or Access the ALPR System?

a. Internal Access

MB limits internal access to the ALPR System and ALPR Information to specific individuals who are authorized for such access and who have a legitimate business purpose for such access (“authorized personnel”). These authorized personnel include the following:

● Select security personnel who may use such ALPR Information in connection with preventing unauthorized use of MB facilities, or in connection with detecting, investigating and preventing activities that may violate MB’s policies, be illegal, or otherwise impact the safety and security of MB’s guests and/or third parties; and

● Select parking and transportation personnel who may use such ALPR Information in connection with enhancing your experience while visiting the Parking Facilities, preventing unauthorized use of the Parking Facilities, or detecting, investigating and preventing activities that may violate MB’s policies or be illegal.

b. External Access

MB will not sell, share, or transfer ALPR Information to a third party, except in limited circumstances, including:

●  To provide service providers with ALPR Information in connection with their performance of services on MB’s behalf; however, these companies are prohibited from using ALPR Information for purposes other than those requested by MB or required by law. The process for sharing ALPR Information with third-party service providers is governed by MB’s contracts with such providers; and

●  To ensure the safety and security of MB’s guests and third parties, to protect MB’s rights and property and the rights and property of MB’s guests and third parties, to comply with legal process, or in other cases if MB believes in good faith that disclosure is required by law.

Why Do We Collect And Use ALPR Information?

ALPR Information is accessed and used solely for the following purposes:

●  Implement MB’s parking policies and practices;

●  Determine correct parking fees;

●  Recognize vehicles of parking pass holders and others with a special relationship to MB;

●  Provide security for the Parking Facilities, or protect our rights;

●  Operate and troubleshoot the ALPR System, security cameras, and network video recorders

●  Identify and track abandoned vehicles;

●  Count and check vehicles parked overnight;

●  Identify stolen vehicles and report them to law enforcement; and

●  Otherwise cooperate with law enforcement agencies, government requests, subpoenas, court orders, or legal process.

We also may use ALPR Information to enforce our rights or as needed support for external auditing, compliance, and corporate governance functions.

How Are People Trained On How To Use The ALPR System?

MB trains authorized personnel who have a business reason to interact with ALPR Information on the sensitivity of ALPR Information and the procedures that MB has put in place to protect it.

Training content includes privacy protections for ALPR Information, appropriate use of the ALPR System, ALPR technological capabilities and associated risks, and ALPR Information security measures.

How Do We Make Sure The ALPR Information Is Accurate?

MB will take reasonable measures to ensure the accuracy of ALPR Information generated by the ALPR System, but cannot guarantee 100% accuracy.  Should it be deemed necessary by MB, MB will check to confirm that the plate characters matched by the ALPR System correspond with the digital image of the license plate in question.  Further, should it be deemed necessary by MB, MB will aim to correct mistaken translations and other database errors if those errors are identified and confirmed. MB and its providers also employ reasonable technical measures, including regular testing, to check the accuracy of ALPR Information.

How Will We Monitor And Secure The ALPR Information?

MB will use operational, administrative, technical, and physical safeguards and procedural and personnel security measures to monitor and secure ALPR Information, and to protect ALPR Information from unauthorized access, use, modification, disclosure, or destruction. The Internet and our services are not 100% secure, however, so complete security of the ALPR system is not guaranteed.

Who Is The Official Custodian and Owner Of The ALPR Information And ALPR System?

The official custodian and owner of the ALPR Information and ALPR System is MB.

How Long Do We Keep ALPR Information?

MB retains ALPR Information for as long as necessary for the purposes listed above and regularly destroys ALPR Information when MB determines its retention is no longer necessary, unless MB is informed that it must retain the ALPR Information in accordance with legal process or to satisfy other legal obligations.

How Will You Know If This Policy Has Changed?

Changes to this Policy may be made from time to time by MB. Any changes to the Policy will take effect upon posting, and will apply to all ALPR Systems and ALPR Information, regardless of when it was collected, in accordance with applicable law. We will display the “Updated” date above so you can check this Policy for any recent update.

For more information, contact MB at [email protected].